BNKA

Document 1 of 8 of the BNKA Documentary Package, Edition 1.0
Effective date: July 2026
Scope: all jurisdictions
Contact: legal@bnka.com
Supersedes: any previous version of general terms published on bnka.com

1. PURPOSE AND SCOPE

1.1 These General Terms govern solely the use of the software: the technology platform identified by the trade mark BNKA (the "Platform"), comprising the bnka.com website, the mobile applications and the associated digital interfaces.

1.2 These General Terms do not govern any financial service.

1.3 The Platform constitutes solely a technology interface enabling the User to access services provided by duly authorised third parties where applicable.

1.4 These General Terms apply to every User of the Platform, in any jurisdiction, and are supplemented by the Jurisdiction Module corresponding to the User's country of residence.

1.5 "BNKA" is a trade mark. It does not designate any entity providing financial services.

2. DOCUMENTARY STRUCTURE

2.1 The relationship is governed by the following documents:

Document	Content	Issued by
General Terms	Use of the Platform, common to all jurisdictions	Byte Neoka
Jurisdiction Module	Participating entities, functionalities enabled, local specificities	Byte Neoka
Corridor Annex	Entities participating in each cross-border payment corridor	Byte Neoka
Regulated Entity's Agreement	Product or account, transactions, pricing, liability, safeguarding of funds, complaints	The Regulated Entity
Legal Notice	Full corporate identification	Byte Neoka
Fee schedule	Fees and charges, at bnka.com/fees	The Regulated Entity
Privacy Policy	Processing of personal data	Byte Neoka

2.2 Order of precedence.

1. The Regulated Entity's Agreement prevails over any other document in all matters relating to the products and financial services.
2. The Jurisdiction Module and the Corridor Annex prevail over these General Terms in matters specific to their scope.
3. These General Terms govern all other matters.

2.3 The Jurisdiction Modules and Corridor Annexes in force are those published on bnka.com from time to time. Functionalities will be available only in those jurisdictions for which a Module has been published.

2.4 Principle of non-duplication. Neither these General Terms, nor the Jurisdiction Modules, nor the Corridor Annexes reproduce, amend, interpret or supplement the content of the Regulated Entity's Agreement. Information relating to the product or account, to its nature, to its safeguarding or backing, to coverage by deposit guarantee schemes, to limits, to remuneration, to execution times, to the Regulated Entity's fees, to the regime governing unauthorised transactions, to termination and to the complaints procedure is set out exclusively in that Agreement. Any discrepancy is resolved in favour of the Regulated Entity's Agreement.

3. IDENTIFICATION

3.1 Owner of the Platform. The Platform is owned by Neoxpat Limited, a company incorporated under the laws of the Republic of Cyprus, registration number HE 444502 ("Neoxpat"). Neoxpat owns the Platform and the intellectual property rights in it. Neoxpat does not provide financial services.

3.2 Provider of the software service. The Platform is developed, operated and maintained by Byte Neoka UAB, a company incorporated under the laws of the Republic of Lithuania, registration code 306008409 ("Byte Neoka"), technical operator of the Platform and the User's sole counterparty under these General Terms.

3.3 Regulated Entity. The products and financial services accessible through the Platform are provided by an entity duly authorised and supervised in each jurisdiction (the "Regulated Entity"), identified in the corresponding Jurisdiction Module and in its own Agreement.

3.4 The full identification and contact details of Neoxpat, of Byte Neoka and of the group's local entities, including their registered offices, are set out in the Legal Notice published on bnka.com and in the relevant public registers.

4. NATURE OF THE SERVICE PROVIDED BY BYTE NEOKA

4.1 Under these General Terms, Byte Neoka provides the User solely with:

(a) a licence to use the Platform in accordance with clause 7;
(b) the display of the information which the Regulated Entity makes available through the interface;
(c) the technical transmission to the Regulated Entity of the instructions which the User submits through the interface;
(d) technical support concerning the operation of the software.

4.2 Byte Neoka provides solely technology services relating to the operation of the Platform. It does not provide regulated financial services, which are offered exclusively by the corresponding Regulated Entity.

4.3 In particular, Byte Neoka is not a credit institution, an electronic money institution or a payment institution; it does not take deposits or other repayable funds from the public; and it does not at any time come into possession of the User's funds, nor does it safeguard, control or dispose of them.

4.4 Crypto-assets. Under these General Terms, Byte Neoka does not provide the User with crypto-asset services. The User does not acquire, hold, transfer or assume exposure to crypto-assets through the Platform. The amounts shown in the interface are denominated and settled exclusively in fiat currency, and the amount payable by the User and the amount to be received by the beneficiary are determined at the time each order is confirmed.

4.5 The decision to accept or reject the User as a client of the Regulated Entity rests exclusively with that entity.

4.6 Byte Neoka does not provide financial, investment, legal or tax advice.

5. THE PRODUCTS AND FINANCIAL SERVICES ARE PROVIDED BY THE REGULATED ENTITY

5.1 The products and financial services are provided in full by the Regulated Entity, under its own authorisation, its own responsibility and its own Agreement. The User enters into a direct and independent contract with the Regulated Entity. Neither Byte Neoka nor Neoxpat is a party to that contract.

5.2 The following rest exclusively with the Regulated Entity:

• identification of the User and the decision to accept or reject;
• opening, maintenance, suspension and closure of the product or account;
• issuance of the electronic money or equivalent instrument, and allocation of the corresponding account identifier;
• execution of transactions and compliance with execution times;
• safeguarding or backing of the funds;
• the pre-contractual and contractual information required by the applicable rules;
• handling of unauthorised or incorrectly executed transactions, and refunds;
• handling of complaints relating to the products and financial services.

5.3 Before contracting, the User must read and accept the Regulated Entity's Agreement, which identifies that entity, its authorisation or registration number and its supervisory authority.

5.4 The User's funds do not form part of the balance sheet or assets of Byte Neoka or Neoxpat, and are not available to meet the obligations of either.

6. REGISTRATION ON THE PLATFORM

6.1 Natural persons aged eighteen (18) or over who are resident in the countries indicated as available on the Platform may register. These General Terms do not enable contracting by legal persons.

6.2 Registration on the Platform is a technical act and does not give rise to any right to the opening of a product or account.

6.3 Where the Regulated Entity requires identification documents, the Platform may serve as a technical channel for their collection and transmission. Verification, assessment and the decision rest with the Regulated Entity.

6.4 The User undertakes to provide accurate, complete and up-to-date information, and to notify any change without delay.

7. LICENCE TO USE

7.1 Byte Neoka, with the authorisation of Neoxpat, grants the User a limited, non-exclusive, non-transferable, revocable and non-sublicensable licence to use the Platform for personal purposes in accordance with these General Terms.

7.2 The User may not decompile, reverse engineer, extract the source code from, replicate the Platform, access it by unauthorised automated means, circumvent security measures, or use the Platform for unlawful or fraudulent purposes.

8. AVAILABILITY AND CONTINUITY

8.1 The Platform is provided on a reasonable availability basis. Byte Neoka does not warrant uninterrupted or error-free operation and may suspend access for maintenance, updates, security incidents or at the requirement of a competent authority.

8.2 Suspension of access to the Platform does not affect the User's rights or obligations vis-à-vis the Regulated Entity, nor the availability of the User's funds, which continue to be governed by the Regulated Entity's Agreement and by the channels which that entity makes available.

9. SUPPORT AND COMPLAINTS

9.1 Enquiries and incidents concerning the operation of the software may be addressed to support@bnka.com or to the support channels indicated on the Platform from time to time.

9.2 Complaints relating to the product or account, to transactions, to pricing, to unauthorised transactions or to any other aspect of the products and financial services must be addressed to the Regulated Entity, through the channels and in accordance with the procedure and time limits set out in its Agreement and in the applicable rules.

9.3 Where the User addresses a complaint of that nature to Byte Neoka, Byte Neoka will forward it to the Regulated Entity and notify the User accordingly, without this altering the allocation of responsibilities set out in clause 5.

9.4 The Jurisdiction Modules identify the additional complaint channels and the competent administrative bodies in each country.

10. DATA PROTECTION

Personal data is processed in accordance with the rules applicable in each jurisdiction and with the Privacy Policy, accessible on the Platform and forming an integral part of these General Terms.

11. INTELLECTUAL PROPERTY

The intellectual and industrial property rights in the Platform, including the software, the BNKA trade mark, the content and the design, belong to Neoxpat or have been licensed to it. Nothing in these General Terms transfers any right in them to the User.

12. LIABILITY

12.1 Byte Neoka's liability is limited to the proper functioning of the software in accordance with these General Terms.

12.2 Byte Neoka is not liable for the acts or omissions of the Regulated Entity, for the decisions taken by that entity concerning the acceptance of the User, the product or the transactions, or for the economic consequences arising from the products and financial services.

12.3 To the extent permitted by law, Byte Neoka will not be liable for indirect or consequential loss, or for interruptions attributable to third parties or to causes beyond its reasonable control.

12.4 Nothing in these General Terms excludes or limits liability which cannot be excluded or limited under mandatory provisions, nor does it affect the User's non-waivable rights as a consumer.

13. DURATION, AMENDMENT AND TERMINATION

13.1 These General Terms are entered into for an indefinite term.

13.2 Amendments will be notified with reasonable advance notice and published on the Platform. The specific notice periods required in each jurisdiction are set out in the corresponding Module.

13.3 The User may cease using the Platform and request deletion of the User's technical profile at any time. This does not of itself terminate the relationship with the Regulated Entity, which must be terminated in accordance with that entity's Agreement.

13.4 Byte Neoka may terminate the licence to use in the event of breach of these General Terms, unlawful or fraudulent use, or at the requirement of a competent authority.

14. REQUESTS FROM AUTHORITIES

Byte Neoka and Neoxpat will provide, each in respect of the information available to it, to any competent judicial, administrative, supervisory or anti-money-laundering authority, upon request and to the extent legally required, the full identification of the Regulated Entity, of the other participating entities and of the contractual relationships in place, together with such information and documentation as may be requested of them.

15. ASSIGNMENT AND SUBCONTRACTING

Byte Neoka may subcontract technical functions to group entities or to third parties, without altering its obligations towards the User. The User may not assign its rights or obligations without prior written consent.

16. LANGUAGE, GOVERNING LAW AND JURISDICTION

16.1 The Spanish version is the reference version.

16.2 These General Terms are entered into between the User and Byte Neoka UAB and are governed by the law of the Republic of Lithuania, being the domicile of the provider of the service contracted, without prejudice to the mandatory consumer protection provisions of the User's country of habitual residence and to the provisions of the applicable Jurisdiction Module.

16.3 Disputes relating to the use of the Platform will be submitted to the competent courts of the Republic of Lithuania. A User who is a consumer retains the right to bring and to defend proceedings before the courts of the User's place of habitual residence.